Ezel / IRS Rulings / 200731030

CCA 200731030: Railroad employer status ended after operations ceased

Number
200731030
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
May 4, 2007
Publicly released
August 3, 2007
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2007, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2007
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

The Railroad Retirement Board reported that a redacted business ceased to be an employer under the railroad retirement and unemployment insurance laws. Chief Counsel agreed that its Railroad Retirement Tax Act employer status ended when it stopped operating. Because the exact cessation date was unknown, the memorandum accepted a different effective date shown only as a redaction in the public copy. Chief Counsel asked the IRS processing unit to take the corresponding action.

Ruling snapshot

  • Question: When did the business cease to be an employer under the Railroad Retirement Tax Act?
  • Outcome: Status ended when operations ceased; the accepted effective date is redacted.
  • Key authorities: IRC § 3231; Railroad Retirement Tax Act.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200731030
Release Date: 8/3/2007
CC:TEGE:EOEG:ET1
POSTN-111261-07

UILC: 3231.01-00

date: May 04, 2007
to: Director, Submission Processing
Cincinnati, OH
Attn: Entity Unit

from: Office of Division Counsel/Associate Chief Counsel Tax Exempt & Government Entities

subject: Railroad Retirement Tax Act Status

In accordance with the coordination procedure established between the Service and the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that the following business ceased to be an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective --------------------------:

----------------------------
--------------------------------
-----------------------------------------
----------------------------------------

We have reviewed the opinion of the RRB and, based upon the information submitted to us by the RRB, we also conclude that ----------------------------. ceased to be an employer under the Railroad Retirement Tax Act when it ceased operations in -------, exact date unknown. Accordingly, we agree to treat the effective date as --------------------------.
Please take the appropriate action regarding this business.

_____
Janine Cook

-----------------------------

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